Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Raymond Antonio Lewis was convicted by a jury of being a felon in possession of a firearm and possession of methamphetamine with intent to distribute. The incident occurred on December 20, 2018, when Officer John Buford responded to a report of shots fired and encountered Lewis, who was found with firearms and methamphetamine. Lewis was identified as a felon and arrested.The United States District Court for the Eastern District of Arkansas handled the case. Lewis was indicted in May 2021, with a superseding indictment in November 2022. His trial was delayed multiple times due to continuance requests by his counsel and other procedural matters. Lewis filed motions to suppress Officer Buford’s testimony and to sever the trial, both of which were denied by the district court. The jury found Lewis guilty on two counts but acquitted him on a third count of possessing firearms in furtherance of drug distribution. He was sentenced to 156 months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Lewis argued that the district court erred in denying his pretrial motions, that the preindictment delay violated his Fifth Amendment rights, that the delay between indictment and trial violated his Sixth Amendment rights, and that the evidence was insufficient to support his conviction. The Eighth Circuit affirmed the district court’s decisions, holding that the exclusionary rule did not apply to the officer’s testimony despite the policy violation, that the denial of the motion to sever was not an abuse of discretion, that the preindictment delay did not violate due process, and that the delay in trial did not violate the Sixth Amendment. The court also found the evidence sufficient to support the convictions. View "United States v. Lewis" on Justia Law

In 2020, Mujera Benjamin Lung’aho threw Molotov cocktails that damaged or destroyed three police cars belonging to state and municipal police departments. He was indicted under 18 U.S.C. § 844(f)(1) for maliciously destroying law enforcement vehicles possessed by local police departments receiving federal financial assistance. Lung’aho moved to dismiss the indictment, arguing that the statute was unconstitutional as applied to him.The United States District Court for the Eastern District of Arkansas denied Lung’aho’s motion to dismiss. The court held that while the Property Clause did not apply because the police cars were not federal property and were not bought with federal financial assistance, the prosecution was constitutional under the Spending Clause coupled with the Necessary and Proper Clause.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss de novo. The court held that Lung’aho’s conduct fell within the plain meaning of 18 U.S.C. § 844(f)(1) and that the statute was constitutional as applied to him. The court reasoned that under the Spending Clause and the Necessary and Proper Clause, Congress has the authority to ensure that federal funds are spent for the general welfare, and criminalizing the arson of police cars from departments receiving federal funding is a rational means of safeguarding federal dollars. The court affirmed the district court’s judgment, concluding that § 844(f)(1) was constitutionally applied to Lung’aho. View "United States v. Lung'aho" on Justia Law

Two students alleged that an Arkansas law violates their First Amendment rights by prohibiting their teachers from providing classroom materials and instruction about Critical Race Theory (CRT). The district court concluded that the law likely violated the students' right to receive information and entered a preliminary injunction. Arkansas officials appealed, arguing that the Free Speech Clause does not allow students to compel the government to provide certain classroom materials or instruction in public schools.The United States District Court for the Eastern District of Arkansas granted a preliminary injunction to the students but denied one to the teachers. The court determined that the teachers' speech was government speech, not their own, and thus any chill on their speech did not harm their rights. The court concluded that the students demonstrated that the law blocked their receipt of information previously provided before its enactment and that the Arkansas officials did not show a legitimate pedagogical reason for withholding teaching about CRT.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the Arkansas officials. The court held that the students conceded the classroom materials and instruction they sought to receive constituted government speech. Since the government's own speech is not restricted by the Free Speech Clause, the government is free to choose what to say and what not to say. The court concluded that the students could not show a likelihood of success on their claim and vacated the preliminary injunction. The court also declined to uphold the preliminary injunction based on the teachers' vagueness claim, as the teachers did not file a cross-appeal. The case was remanded for further proceedings. View "Walls v. Oliva" on Justia Law

In several Minnesota cities, only members of a pre-approved union can work on municipal construction jobs. Multiple contractors, a carpenter, and a union objected to this requirement, alleging it violated the First Amendment. The contractors, Kaski, Inc.; Nordic Group, Inc.; and Roen Salvage Co., claimed they missed out on lucrative work due to these project-labor agreements. Luke Krhin, a carpenter, and the Christian Labor Association, which has a local chapter in Minnesota, also joined the lawsuit.The United States District Court for the District of Minnesota determined that none of the plaintiffs had standing to sue. The court found that the contractors, Krhin, and the Christian Labor Association could not succeed on their First Amendment claim. The plaintiffs appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on the issue of standing, a jurisdictional requirement. The court found that the contractors did not have standing because the relevant constitutional claims belonged to their employees, not to them. The court also found that Krhin, who opposed joining a pre-approved union, was exempt from the requirement as a supervisor, thus lacking standing. The Christian Labor Association also lacked standing because it failed to identify any members who would have standing to sue in their own right.The Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss based on a lack of standing. View "Christian Labor Association v. City of Duluth" on Justia Law

Law enforcement officers suspected Bandak Wiyual Deng of involvement in a shooting at a park on February 10, 2022. Surveillance video showed an individual matching his characteristics exiting a car with what appeared to be a gun. The car, a black Ford Taurus, lacked a license plate or paper registration tag. A confidential informant recorded a conversation with Deng, where Deng mentioned needing a gun for a funeral and a previous shooting. On the day of the funeral, officers stopped Deng, found marijuana and a gun in his car, and Deng admitted to using drugs and touching the gun.The United States District Court for the Southern District of Iowa upheld the government's peremptory strikes of two prospective jurors and refused to admit parts of Deng's interview with law enforcement. Deng's motion for a judgment of acquittal, arguing that 18 U.S.C. § 922(g)(3) violated the Second Amendment, was denied. The jury convicted Deng.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not clearly err in overruling Deng’s objections to the peremptory strikes, as the government provided race-neutral explanations. The court also found that any potential error in the district court's evidentiary rulings was harmless, given the ample evidence supporting Deng’s conviction. Finally, the court affirmed the denial of Deng’s motion for a judgment of acquittal, rejecting his facial challenge to the constitutionality of 18 U.S.C. § 922(g)(3). The judgment was affirmed. View "United States v. Deng" on Justia Law

Dimaryn Ware was indicted on multiple firearms-related charges. He moved to dismiss the indictment, arguing that the statutes violated the Second Amendment both on their face and as applied to him. The district court denied his motion, and Ware pled guilty while preserving his right to appeal the denial. He now appeals the denial and several sentencing decisions.The district court, the United States District Court for the Southern District of Iowa, denied Ware's motion to dismiss the indictment. Ware pled guilty to two counts, and the remaining counts were dismissed on the government's motion. At sentencing, the court applied the Base Offense Level from the United States Sentencing Guideline (USSG) § 2K2.1(a)(3), concluding that the offense involved a firearm capable of accepting a large capacity magazine. The court calculated a Guidelines range of 84 to 105 months but varied upward to 144 months' imprisonment, ordering the sentence to run concurrently with a state sentence for a related shooting but consecutively to other state sentences for unrelated offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Ware's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and § 932(b)(1) were foreclosed by precedent, specifically citing United States v. Jackson and United States v. Sharkey. The court also held that the district court did not err in considering conduct underlying an acquitted charge when determining Ware's sentence, as permitted by precedent. Additionally, the court found no clear error in the district court's application of USSG § 2K2.1(a)(3) based on the evidence of the firearm's capability to accept a large capacity magazine. Finally, the court upheld the district court's decision to impose Ware's federal sentence consecutively to his unrelated state sentences and to not reduce his federal sentence based on time served for those unrelated state sentences.The judgment of the district court was affirmed. View "United States v. Ware" on Justia Law

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

The case involves a group of in-state and out-of-state precious metal traders and their representatives (the "Bullion Traders") challenging Minnesota Statutes Chapter 80G, which regulates bullion transactions. The Bullion Traders argued that the statute violated the dormant Commerce Clause due to its extraterritorial reach, as defined by the term "Minnesota transaction."The United States District Court for the District of Minnesota initially found that Chapter 80G violated the dormant Commerce Clause. The case was then remanded by the United States Court of Appeals for the Eighth Circuit for a severability analysis. The district court concluded that striking portions of the "Minnesota transaction" definition cured the extraterritoriality concern and complied with Minnesota severability law.The Bullion Traders appealed, arguing that the severed statute still applied extraterritorially and that the district court erred in applying Minnesota severability law. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court found that the severed definition of "Minnesota transaction" no longer regulated wholly out-of-state commerce and that the statute, as severed, was complete and capable of being executed in accordance with legislative intent.The Eighth Circuit held that the district court correctly severed the extraterritorial provisions from Chapter 80G, and the remaining statute did not violate the dormant Commerce Clause. The court also agreed that the severed statute complied with Minnesota severability law, as the valid provisions were not essentially and inseparably connected with the void provisions, and the remaining statute was complete and executable. The judgment of the district court was affirmed. View "Styczinski v. Arnold" on Justia Law

Principal Springer was involved in drug dealing within 1,000 feet of a school and had multiple firearms in his apartment. Following a lengthy investigation, a search of his apartment revealed drugs, drug paraphernalia, and firearms. He was charged with conspiring to deal drugs within a school zone and unlawfully possessing firearms due to his drug use and a prior misdemeanor domestic-violence conviction. Springer moved to dismiss the firearm count, arguing that the restrictions violated the Second Amendment. The district court disagreed, and Springer pleaded guilty while reserving the right to appeal his Second Amendment challenges. He was sentenced to 110 months in prison.The United States District Court for the Northern District of Iowa denied Springer’s motion to dismiss the firearm count. Springer then pleaded guilty but reserved his right to appeal the Second Amendment issues. He received concurrent sentences of 110 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the statute prohibiting drug users from possessing firearms, 18 U.S.C. § 922(g)(3), is not facially unconstitutional, referencing its previous decision in United States v. Veasley. The court also rejected Springer’s as-applied challenge to the statute prohibiting domestic abusers from possessing firearms, 18 U.S.C. § 922(g)(9), noting that a conviction under any one of the § 922(g) categories is sufficient. Additionally, the court found no abuse of discretion in the district court’s decision not to grant a downward variance in sentencing. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Springer" on Justia Law

Arkansas Act 629 criminalized many previously legal hemp products. A coalition of affected businesses sued state officers, alleging that Act 629 is unconstitutional. The district court granted the plaintiffs' motion for a preliminary injunction and denied the state's motion to dismiss the Governor and Attorney General.The United States District Court for the Eastern District of Arkansas found that the plaintiffs were likely to succeed on the merits of their Supremacy Clause and due process claims. The court concluded that the 2018 Farm Bill likely preempted Act 629 and that the Act was likely void for vagueness. The court also found that the Governor and Attorney General were not entitled to sovereign immunity because they were sufficiently connected to the enforcement of Act 629.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the 2018 Farm Bill did not expressly preempt Act 629 because the Act's savings clause allowed for the continuous transportation of hemp through Arkansas. The court also found that Act 629 did not conflict with the 2018 Farm Bill's purpose of legalizing hemp production, as the federal law allows states to regulate hemp production more stringently. Additionally, the court concluded that Act 629 was not unconstitutionally vague, as the terms "continuous transportation," "synthetic substance," and "psychoactive substances" were sufficiently clear.The court further held that the Governor and Attorney General were entitled to sovereign immunity because they did not have a sufficient connection to the enforcement of Act 629. The court vacated the preliminary injunction, reversed the order denying the motion to dismiss the Governor and Attorney General, and remanded the case for further proceedings. View "Bio Gen LLC v. Sanders" on Justia Law